Clark v. Angiulli, Inc.

CourtOhio Court of Appeals
DecidedJune 17, 2026
DocketC-250346
StatusPublished

This text of Clark v. Angiulli, Inc. (Clark v. Angiulli, Inc.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Clark v. Angiulli, Inc., (Ohio Ct. App. 2026).

Opinion

[Cite as Clark v. Angiulli, Inc., 2026-Ohio-2281.]

IN THE COURT OF APPEALS FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

ALEX CLARK, : APPEAL NO. C-250346 TRIAL NO. A-2304666 Plaintiff-Appellant, :

vs. : JUDGMENT ENTRY ANGIULLI, INC., d.b.a. MARTINO’S : ON VINE,

Defendant-Appellee. :

This cause was heard upon the appeal, the record, the briefs, and arguments. For the reasons set forth in the Opinion filed this date, the judgment of the trial court is affirmed in part and reversed in part, and the cause is remanded. Further, the court holds that there were reasonable grounds for this appeal, allows no penalty, and orders that costs be taxed 50 percent to the appellant and 50 percent to the appellee. The court further orders that (1) a copy of this Judgment with a copy of the Opinion attached constitutes the mandate, and (2) the mandate be sent to the trial court for execution under App.R. 27.

To the clerk: Enter upon the journal of the court on 6/17/2026 per order of the court.

By:_______________________ Administrative Judge [Cite as Clark v. Angiulli, Inc., 2026-Ohio-2281.]

IN THE COURT OF APPEALS FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

ALEX CLARK, : APPEAL NO. C-250346 TRIAL NO. A-2304666 Plaintiff-Appellant, :

vs. : OPINION ANGIULLI, INC., d.b.a. MARTINO’S : ON VINE,

Civil Appeal From: Hamilton County Court of Common Pleas

Judgment Appealed From Is: Affirmed in Part, Reversed in Part, and Cause Remanded

Date of Judgment Entry on Appeal: June 17, 2026

Beck Law Center and Kimberly Beck, for Plaintiff-Appellant,

Rendigs, Fry, Kiely & Dennis, LLP, Jonathan P. Saxton and James J. Englert, for Defendant-Appellee. [Cite as Clark v. Angiulli, Inc., 2026-Ohio-2281.]

ZAYAS, Judge.

{¶1} This case presents a question of whether summary judgment in favor of

a bar establishment was proper on claims asserted by a patron for vicarious liability

and premises liability arising from an altercation that occurred one night at the bar

establishment. Plaintiff-appellant Alex Clark, the patron, appeals from the trial court’s

grant of summary judgment in favor of the defendant-appellee Angiulli, Inc, d.b.a

Martino’s on Vine (“Martino’s”), the bar establishment, and argues in a single

assignment of error that the trial court erred in granting summary judgment in favor

of Martino’s on the vicarious-liability and premises-liability claims. For the reasons

that follow, we sustain the assignment of error in part and reverse the trial court’s

grant of summary judgment as to the vicarious-liability claim as genuine issues of

material fact remain to be determined on this claim. As to the premises-liability claim,

we overrule the assignment of error as to this claim and affirm the trial court’s grant

of summary judgment in favor of Martino’s on this claim. The cause is remanded for

further proceedings on the vicarious-liability claim.

I. Background

{¶2} Clark initiated this action against Martino’s, asserting claims for

vicarious liability and premises liability, among others.1 The claims arose from an

alleged altercation that occurred at Martino’s on or about Sunday, August 6, 2023,

between 1:00 a.m. and 2:00 a.m. The altercation was allegedly between Clark and

either Martino’s employees or agents, or other patrons. Martino’s answered the

complaint, asserting a defense—among others—that it was not responsible for

1 The complaint was also filed against John Doe defendants 1-20, and asserted a claim for assault

and battery against the John Doe defendants and a third claim against Martino’s for negligent training and supervision. The trial court found the action against John Does defendants 1-20 never commenced under Civ.R. 3(A) as Clark failed to perfect service on these defendants within one year as required. OHIO FIRST DISTRICT COURT OF APPEALS

independent and unforeseeable actions of third parties, over which it had no control.

Martino’s later moved for summary judgment on Clark’s claims, and the trial court

granted summary judgment in favor of Martino’s.2

{¶3} The trial court entered summary judgment in favor of Martino’s on

Clark’s claim for vicarious liability after finding that Martino’s met its initial burden

to show that the “attackers” were “not employees” of Martino’s and Clark failed to meet

his reciprocal burden to set forth “evidentiary facts” showing that the attackers were

employees. The trial court granted summary judgment in favor of Martino’s on Clark’s

claim for premises liability after finding that “[n]othing in the record demonstrates

that . . . Martino’s could have foreseen the type of assault that occurred in this case.”

Clark now appeals.

II. The Summary-Judgment Record

A. The Arguments

{¶4} Martino’s moved for summary judgment on Clark’s claims, arguing that

there “is no question” that the individuals who “interacted with” Clark that night were

not employed by Martino’s, nor were they agents of Martino’s, and it was not

foreseeable that such an altercation “with patrons” would occur. The motion was

supported by an affidavit from the bar manager and several depositions, including

those of Clark, the bartender, the bar manager, and another bar employee.

{¶5} Clark responded in opposition to summary judgment, arguing that

genuine issues of material fact remain as to whether “the assailants” were employed

by Martino’s and whether Martino’s owed Clark a duty as an invitee to prevent a

“foreseeable harm” once the fight began and was therefore required to stop the fight

2 The trial court also granted summary judgment in favor of Martino’s on Clark’s claim for negligent

training and supervision. Clark does not challenge this ruling on appeal.

4 OHIO FIRST DISTRICT COURT OF APPEALS

as soon as possible, which Martino’s did not do where the bartender walked away from

the assault and never addressed the assailants at all and where the bar manager

“handed” Clark back to one of the assailants. In other words, Clark asserted that

Martino’s had a duty to stop the fight after it started as the risk of harm from an

ongoing assault was foreseeable. The response relied upon the same evidence

submitted by Martino’s, as well as an affidavit from Clark’s counsel.

{¶6} Martino’s filed a reply in support of its summary-judgment motion,

arguing that the evidence could only reveal that the individuals in question were not

employees or agents of Martino’s and that the duty to stop an ongoing fight is not

supported by Ohio law as Ohio law uses the totality-of-the-circumstances test to

determine foreseeability.

B. The Evidence

1. Affidavit of the Bar Manager

{¶7} The bar manager of Martino’s is the custodian of the surveillance videos

that are kept as part of his file and maintained in the ordinary course of business. The

bar manager averred that retaining and obtaining surveillance footage of incidents

that occur at Martino’s is part of his duties as the manager of Martino’s, and he

obtained a video of the incident at issue this matter. He claimed that the video was a

fair and accurate depiction of the events that occurred and the time and date stamps

are true and accurate and reflect the actual timing of the events displayed.

2. The Video

{¶8} The video appears to be an excerpt of the surveillance video. There are

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